- 2 - The issues for decision are: (1) Whether petitioner is collaterally estopped from denying that he received bribe income during the years in issue. We hold that he is not. (2) Whether petitioner received unreported bribe income during the years in issue. We hold that he did. (3) Whether petitioner is liable for additions to tax for fraud pursuant to section 6653(b).1 We hold that he is. (4) Whether respondent is precluded from assessing tax for the years in issue due to the running of the statute of limitations. Due to our holding in issue 3 above, we hold that she is not. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and attached exhibits are incorporated herein by this reference. At the time the petition herein was filed, petitioner resided in Pompano Beach, Florida. Petitioner Petitioner received a Bachelor of Science degree in accounting from the Drexel Institute of Technology in 1949. From 1953 to January of 1981, petitioner was employed as a Revenue Agent with the Examination Division of the Philadelphia Office of the Internal Revenue Service (IRS). As a revenue agent, petitioner was responsible for conducting examinations of filed 1 All section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011